- Is this premature when we barely use AI yet?
- It is cheaper now. A register of four tools takes days. The same register after two years of departmental purchases takes weeks and produces arguments about who authorised what. The policy also prevents the expensive mistake happening while you decide, which is staff pasting customer records into public tools. Most of the work is deciding what you will not allow, and that does not depend on scale.
- Will this stop our teams using AI at all?
- The opposite happens more often. People hold back because nobody has told them what is permitted, so the useful low-risk uses never start. Naming the harmless categories in writing releases them. What the framework blocks is narrow: decisions where a wrong answer reaches a customer, a regulator or a payment with no human in between. Those are refused explicitly rather than by nervous silence.
- Can you certify us to ISO/IEC 42001?
- No, and no consultancy can. Certification is issued by an accredited certification body after an audit, and that auditor must be independent of whoever built the system. What we do is align your policies, controls and evidence to the structure of the standard so an audit finds them where it expects to. If you intend to certify, say so early: it changes what evidence we keep from day one.
- Who is liable when the model gets it wrong?
- Your company is, in front of your customer and your regulator, whatever the supplier terms say. That is why the framework starts with a named internal reviewer rather than with vendor selection. The contract matters second, and we read it: what the supplier logs, whether they train on your data, and what notice they give before changing a model underneath you.
- What ongoing work does this leave us with?
- A quarterly review, a register somebody updates when a tool is added, and a reviewer's time on the uses that carry consequence. It is deliberately small, because a control regime heavier than the risk it covers gets abandoned in the first busy month. If a control cannot be run by an ordinary person in an ordinary week, we remove it and record why.